Canada’s 2023 Budget Confirms Global Minimum Tax Implementation

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In yesterday’s 2023 Canadian Budget, the government confirmed that it will introduce legislation implementing the Income Inclusion Rule (IIR) and a domestic minimum top-up tax (QDMTT) applicable to Canadian entities of MNEs with effect for fiscal years of MNEs that begin on or after December 31, 2023.

Germany Publishes Draft Global Minimum Tax Legislation

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On March 20, 2023, the German Federal Ministry of Finance published a consultation, including a draft law (the Minimum Taxation Directive Implementation Act) to implement the EU Global Minimum Tax Directive. The consultation is open for comments until April 21, 2023.

Deferred Tax Data Points For The Pillar 2 GloBE Rules

data points for the substance-based income exclusion

Many of the deferred tax data points are not stand-alone data sources but arise as a result of further calculations that are themselves based on underlying data-sources. There is therefore a ‘layering-up’ of data before the GloBE calculations can be effectively made.